NOTICE OF DISCIPLINARY ACTION

FILE NO.:

CBOT 18-1039-BC

MEMBER:

Charles Mensh

CBOT RULE VIOLATION:

Rule 575 DISRUPTIVE PRACTICES PROHIBITED

All orders must be entered for the purpose of executing bona fide transaction. Additionally, all non-actionable messages must be entered in good faith for legitimate purposes.

A. No person shall enter or cause to be entered an order with an intent, at the time of order entry, to cancel the order before execution or to modify the order to avoid execution.

FINDINGS:

Pursuant to an offer of settlement in which Charles Mensh (“Mensh”) neither admitted nor denied the rule violation upon which the penalty is based, on December 19, 2019, a Panel of the Chicago Board of Trade Business Conduct Committee (“Panel”) found that between calendar dates September 27, 2018, and October 4, 2018, Mensh entered and cancelled orders in the November 2018 Soybean, December 2018 Soybean Oil, December 2018 Soybean Meal, December 2018 Chicago SRW Wheat, and December 2018 KC HRW Wheat futures markets without the intent to trade. Specifically, the Panel found that Mensh layered orders on one side of the order book and cancelled them after his resting smaller orders on the opposite side of the book were executed. The Panel concluded that Mensh thereby violated CBOT Rule 575.A.

PENALTY:

In accordance with the settlement offer, the Panel ordered Mensh to pay a $30,000 fine. The Panel also suspended Mensh from access to any trading floor owned or controlled by CME Group and from direct and indirect access to any designated contract market, derivatives clearing organization or swap execution facility owned or controlled by CME Group for 15 business days, beginning on the effective date below and continuing through and including January 14, 2020.

EFFECTIVE DATE:

December 23, 2019